Add to ORKGAcquisitive reorganizations either by consolidation or statutory merger have become a popular means for corporations with surplus cash or treasury stock to diversify their investment base. The tax treatment of cash received during such reorganizations is an often litigated and still unsettled area of the law. Such confusion is the product of inconsistent and irreconcilable case holdings and Revenue Rulings as the courts and the Internal Revenue Service have attempted to apply the myriad of judicial doctrines and intricate Code law dealing with this question to various factual situations
Redemption and salvation are doctrinal terms suggestive of the enthusiasm of the camp meeting. It is...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
Plaintiff held common and preferred stock of the Gulf States Paper Corporation. In 1942 plaintiff re...
The United States Supreme Court in Turnbow v. Commissioner may have interpreted the Internal Revenue...
A stock-for-stock reorganization which qualifies under IRC section 368(a)(1)(B) accords tax-free tre...
Distributions implies that we are concerned with the tax problems of the stockholder rather than th...
The recent Supreme Court decision in Le Tulle v. Scofield, disapproving the views of four out of fiv...
Taxpayer was the sole stockholder of International Dairy Supply Company. In 1952, Foremost Dairies, ...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
Among the sections added to the revised version of the Internal Revenue Code of 1954 was section 306...
Throughout most of the twentieth century, federal tax laws have permitted nonrecognition of gain in ...
If specified conditions are satisfied, the Internal Revenue Code provides nonrecognition for gain or...
Petitioner owned more than three-fourths of the stock in a corporation whose shares had a par value ...
Section 356(a)(2) of the Internal Revenue. Code requires the recipient of boot in a corporate reorga...
In connection with income taxation, some importance is attached to the difference between mergers an...
Redemption and salvation are doctrinal terms suggestive of the enthusiasm of the camp meeting. It is...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
Plaintiff held common and preferred stock of the Gulf States Paper Corporation. In 1942 plaintiff re...
The United States Supreme Court in Turnbow v. Commissioner may have interpreted the Internal Revenue...
A stock-for-stock reorganization which qualifies under IRC section 368(a)(1)(B) accords tax-free tre...
Distributions implies that we are concerned with the tax problems of the stockholder rather than th...
The recent Supreme Court decision in Le Tulle v. Scofield, disapproving the views of four out of fiv...
Taxpayer was the sole stockholder of International Dairy Supply Company. In 1952, Foremost Dairies, ...
The Courts of Appeals for the Sixth and Ninth Circuits are in conflict on the question of whether se...
Among the sections added to the revised version of the Internal Revenue Code of 1954 was section 306...
Throughout most of the twentieth century, federal tax laws have permitted nonrecognition of gain in ...
If specified conditions are satisfied, the Internal Revenue Code provides nonrecognition for gain or...
Petitioner owned more than three-fourths of the stock in a corporation whose shares had a par value ...
Section 356(a)(2) of the Internal Revenue. Code requires the recipient of boot in a corporate reorga...
In connection with income taxation, some importance is attached to the difference between mergers an...
Redemption and salvation are doctrinal terms suggestive of the enthusiasm of the camp meeting. It is...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
Plaintiff held common and preferred stock of the Gulf States Paper Corporation. In 1942 plaintiff re...